Retrospective exemption certificates under entry tax law must be fully implemented, and limitation cannot defeat consequential relief.

Retrospective exemption certificates issued under the entry tax exemption scheme must be given full effect for the entire covered period, including reassessment years, when the certificates expressly extend to that period. The tax authorities cannot confine the benefit to selected assessment years once retrospective exemption has been granted. Consequential relief may not be refused on technical limitation grounds where the exemption certificate was issued later, sufficient cause exists for seeking reassessment, and the statutory scheme permits revisional or related corrective powers. The availability of an alternative statutory remedy does not justify inaction where the certificate stands valid and has not been withdrawn or shown to be wrongly issued.

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Issues: (i) whether the exemption certificates granted under the entry tax exemption scheme entitled the assessee to retrospective exemption for the entire eligible period, including the reassessment years in dispute; (ii) whether the authorities could refuse consequential relief on the ground of limitation and availability of alternative statutory remedies.

Issue (i): whether the exemption certificates granted under the entry tax exemption scheme entitled the assessee to retrospective exemption for the entire eligible period, including the reassessment years in dispute.

Analysis: The exemption certificates were issued under the power to grant exemption retrospectively, and the record showed that the assessee had applied for exemption and had pursued the matter after the certificates were granted. Once the certificates were issued with retrospective effect, the departmental authorities were required to give effect to them in letter and spirit. The Court found that the exemption could not be confined to only some assessment years when the certificates covered the entire relevant period.

Conclusion: The assessee was entitled to retrospective exemption for the full covered period, including the disputed reassessment years.

Issue (ii): whether the authorities could refuse consequential relief on the ground of limitation and availability of alternative statutory remedies.

Analysis: The Court held that the exemption certificate itself arose in 2017, so the assessee had sufficient cause to seek consequential reassessment thereafter. It also held that the limitation objection could not defeat the claim in view of the statutory scheme applying the law of limitation to appeals and revision, and that the authorities could have exercised revisional powers to give effect to the exemption. The existence of an alternative remedy did not justify inaction where the exemption certificate had already been granted and no case was made out that it had been withdrawn or wrongly issued.

Conclusion: The limitation objection and the plea of alternative remedy were rejected, and the disputed assessment orders were liable to be set aside.

Final Conclusion: The writ petition succeeded, the assessee was directed to receive the benefit of the exemption certificate for the entire eligible period, and consequential refund and reassessment relief followed.

Ratio Decidendi: A retrospective exemption certificate must be given full effect by the tax authorities, and once such a certificate is issued, consequential relief cannot be denied merely on technical limitation objections where sufficient cause exists and the statutory framework permits extension or revision.

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